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Court Rules
Judge

Judge Thomas D. Long

Individual Rules, Standing Orders & Policies

Rules last changed:
Los Angeles Superior Court

Limits & Logistics

Document Limits

Supplemental Memorandum
5 pgs

Courtesy Copies

Courtesy copies

  • 5 copies • At Trial
  • Email

Exhibits

  • 1 copy • At Final Status Conference

Communication

Email

Chambers

smcdept506@lacourt.ca.gov
Filters:

Page & Word Limits1 rule

Page LimitsMandatory

A supplemental memorandum may not exceed five pages in length.

Supplemental memorandum
Up to 5 pages
Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 9
|SectionSupplemental Memorandum

Document Format Requirements11 rules

FormattingMandatory

Parties must attach tabbed copies of designated transcript pages to the joint chart, highlight each designation with a party-distinct color, and label lodged transcript spines with witness name, date, and volume number.

Court's wording

The parties shall attach copies of the pages of the transcripts of the deposition or former testimony they are designating or counter-designating to the Joint Chart of Page and Line Designations for Deposition and Former Testimony, with numbered tabs separating each deposition or Trial transcript. Each designation or counter-designation shall be highlighted, with each party using a different color highlighter. Deposition transcripts lodged with the Court should be labeled with the witness's name, date, volume number on the spine (e.g., "John Doe, 12/24/20, Vol. 1 of 3"), as well as the case name and number if it fits.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 16
|SectionH. JOINT CHART OF PAGE AND LINE DESIGNATIONS FOR DEPOSITION AND FORMER TESTIMONY
FormattingMandatory

Parties must jointly prepare at least five sets of tabbed, numerically organized three-ring exhibit binders: one for the Court, the Judicial Assistant, the witnesses, and each party.

Binding
Tabbed three-ring binder
Applies to
  • Exhibits

Formatting

  • Jointly prepared by parties' counsel and any self-represented parties
  • Organized numerically

Court's wording

The parties’ counsel and any self-represented parties shall work together to jointly prepare at least five sets of tabbed, exhibit binders organized numerically in three-ring binders (Exhibit Binders): a set for the Court, a set for the Judicial Assistant, a set for the witnesses, and a set for each party.

FormattingMandatory

The Motions in Limine Binder must be marked with the case caption, number, and title, contain conformed copies of all MIL papers, and be organized in tabbed three-ring binders with opposition/reply papers directly behind each motion separated by colored sheets.

Binding
Tabbed three-ring binder
Applies to
  • Motion
  • Opposition
  • Reply

Formatting

  • Tabbed in numerical order

Court's wording

The Motions in Limine Binder shall be marked with the case caption, number, and title on its front and spine and shall include conformed copies of all motions in limine, opposition papers, and reply papers, organized in one or more three-ring binders, tabbed in numerical order with the opposition papers and reply papers for each motion placed directly behind the moving papers with a colored sheet of paper separating the moving, opposition, and reply papers.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 18
|SectionMOTIONS IN LIMINE BINDER
FormattingImportant

The full text jury instructions should be in a form suitable to be provided to the jury. There should be no footers or headers or titles except references to CACI. The party proposing an instruction should not be identified on the instruction and the boxes provided when the tear-off forms were in use should not be used.

Applies to
  • Jury instructions

Formatting

  • Proposing party must not be identified on the instruction
  • Tear-off form boxes must not be used
Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 15
|SectionF. JURY INSTRUCTIONS (JOINT AND CONTESTED)
FormattingImportant

Where the parties have stipulated to the admission of a good number of exhibits, they should prepare an Admitted Exhibits notebook for the clerk.

FormattingImportant

Where a witness will be testifying on a number of exhibits from different volumes, the attorney conducting the direct examination should prepare a notebook for the witness with the exhibits to be used on direct.

FormattingImportant

Exhibits should be three-hole punched in notebooks marked with the case caption, number, and title on the front and spine of the notebook and with each exhibit paginated sequentially at the bottom center of each page. For example, Exhibit 1 should be paginated 1 - 1, 1 - 2, 1 - 3, etc.

Applies to
  • Exhibits

Formatting

  • Exhibits three-hole punched in notebooks
FormattingImportant

Exhibits should be clearly identified as to the party offering them and the parties should use clearly identified number and/or letter sequences to pre-mark exhibits.

FormattingImportant

Where electronic exhibits are being used, each exhibit should be on a separate thumb drive and the parties should stipulate to a clean laptop to be provided to the jury for viewing electronic exhibits and should instruct the courtroom attendant as to its use.

FormattingNote

Although the statement should present the disputed issues as concisely as the subject matter permits, no page limitations apply to statements regarding discovery disputes.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 9
|SectionForm of Joint Discovery Dispute Statement
FormattingNote

The Court permits the parties to propose an alternative identification method, including electronically marked deposition transcripts showing markings, counter-markings, and objections, in lieu of the paper joint chart format.

Court's wording

Alternatively, the Court invites the parties to agree on and propose to the Court a different way of identifying proposed deposition testimony to be used at trial. The Court can work with electronically marked deposition transcripts that present the parties' markings, counter-markings and objections in a way that the Court can efficiently make rulings and a proper record can be made of those rulings.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 16
|SectionH. JOINT CHART OF PAGE AND LINE DESIGNATIONS FOR DEPOSITION AND FORMER TESTIMONY

Document Filing Requirements43 rules

Filing RequirementsMandatory

The Court requires parties to prepare joint statements to brief discovery disputes on motions to compel further responses. See Exhibit A.

Filing RequirementsMandatory

The parties shall arrange for a Trial notebook to be delivered to the courtroom and lodged prior to the FSC. Los Angeles Superior Court, Local Rule 3.25(g). The notebooks should be prepared consistently with the Trial Preparation Order. See Exhibit B.

Filing RequirementsMandatory

If the parties cannot agree on a joint form of the settled statement, they must each submit their own version and must highlight the differences and lodge their competing proposals the next morning before proceedings resume.

Filing RequirementsMandatory

If no court reporter is used, the parties must jointly prepare a summary of the day's proceedings, including a detailed summary of the testimony of any witness, and lodge it in the courtroom the next morning before proceedings resume.

Filing RequirementsMandatory

The joint discovery dispute statement must be set forth in one document signed by both counsel.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 9
|SectionForm of Joint Discovery Dispute Statement
Filing RequirementsMandatory

No other separate memorandum of points and authorities may be filed by either party in connection with the motion.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 9
|SectionSupplemental Memorandum
Filing RequirementsMandatory

The motion shall be supported only by the joint discovery dispute statement and supplemental memoranda described below. No other memoranda of points and authorities shall be filed in support of the motion.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 9
|SectionCommencing a Discovery Motion
Filing RequirementsMandatory

The statement must contain all discovery requests in dispute and, as to each such request, the contentions and points and authorities of each party.

Document
Joint discovery dispute statement

Must include

  • Legal argument
Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 9
|SectionForm of Joint Discovery Dispute Statement
Filing RequirementsMandatory

The title page of the statement must state the discovery cutoff date, the final status conference date, and the trial date.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 9
|SectionForm of Joint Discovery Dispute Statement
Filing RequirementsMandatory

Disputed interrogatories and answers must be quoted verbatim in the joint statement, followed by each party's separately stated contentions.

Court's wording

For example, if the sufficiency of an answer to an interrogatory is at issue, the statement must contain, verbatim, both the interrogatory and the allegedly insufficient answer, followed by each party's contentions as to that particular interrogatory, separately stated.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 9
|SectionForm of Joint Discovery Dispute Statement
Filing RequirementsMandatory

The statement may not refer the Court to any other documents.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 9
|SectionForm of Joint Discovery Dispute Statement
Filing RequirementsMandatory

discuss and prepare the documents required in Sections 3.B. – H., below, and the Motions in Limine Binder, Exhibit Binders, and Trial Binder required in Sections 3 - 5, below

Filing RequirementsMandatory

Counsel and self-represented parties must jointly prepare and file a witness list containing only witnesses actually intended to be called at trial, excluding impeachment or rebuttal witnesses.

Court's wording

The parties' counsel and any self-represented parties shall work together to prepare and file a joint list of all witnesses whom any party actually intends to call at Trial and is actually expected to testify (please do not include other potential witnesses), excluding witnesses being called only for impeachment or rebuttal.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 13
|SectionTrial Procedures - B. Joint Witness List
Filing RequirementsMandatory

The joint witness list must be organized into six specified columns covering witness name/expert status/accommodations, calling party, testimony description, and estimated direct, cross, and total examination times in minutes.

Court's wording

The joint witness list shall be organized with columns (in the format set forth below) which state (1) the name of each witness (in alphabetical order by last name), if the witness is being called to testify as an expert, and any special requirements or accommodations needed for the witness (e.g., interpreter, remote connection), (2) the party calling the witness, (3) a brief description of the witness's expected testimony, (4) an estimate of the length of direct examination (in minutes), (5) an estimate of the length of cross-examination (in minutes), and (6) the total estimated length of examination (in minutes).

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 13
|SectionTrial Procedures - B. Joint Witness List
Filing RequirementsMandatory

At the end of the joint witness list, the parties and any self-represented parties shall add up the estimated times for all witnesses' testimony and state the grand total in the last column in weeks, days, hours and minutes as appropriate.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 13
|SectionTrial Procedures - B. Joint Witness List
Filing RequirementsMandatory

As set forth above, the parties' counsel and any self-represented parties shall meet and confer in an effort to resolve objections to the authenticity and admissibility of each exhibit.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 14
|SectionTrial Procedures - C. Joint Exhibit List
Filing RequirementsMandatory

Counsel and self-represented parties must jointly prepare and file an exhibit list with eight specified columns for each exhibit any party actually intends to offer at trial.

Court's wording

The parties' counsel and any self-represented parties shall work together to prepare and file a joint exhibit list organized with columns (in the format set forth below) which state, as to each exhibit any party actually intends to offer at Trial: (1) the exhibit number, (2) a brief description of the exhibit, (3) which party is offering the exhibit, (4) whether the parties have stipulated to authentication of the exhibit, (5) whether the parties have stipulated to admissibility of the exhibit, (6) any evidentiary objections to admission of the exhibit, (7) the date the exhibit was marked for identification, and (8) the date the exhibit was admitted into evidence.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 14
|SectionTrial Procedures - C. Joint Exhibit List
Filing RequirementsMandatory

For Jury Trials, the parties' counsel and any self-represented parties shall work together to prepare a complete set of full-text proposed jury instructions, editing all proposed Judicial Council of California Civil Jury Instructions (CACI) instructions, inserting party names, and eliminating blanks and other irrelevant or inapplicable material. If there is an appropriate CACI jury instruction on a point of law, the Court expects the parties to request the CACI instruction instead of a specially prepared jury instruction. Any departure from CACI instructions should be clearly explained.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 15
|SectionF. JURY INSTRUCTIONS (JOINT AND CONTESTED)
Filing RequirementsMandatory

For Jury Trials, the parties' counsel and any self-represented parties shall work together to prepare and file a joint proposed general verdict form or a joint proposed special verdict form acceptable to all parties. (Local Rule 3.25, subd. (g)(8).)

Filing RequirementsMandatory

For jury trials, the parties must jointly prepare and file a joint list of proposed jury instructions stating, for each instruction, its number, title, requesting party, agreed/contested status, any objection, and whether it was given.

Court's wording

For Jury Trials, the parties' counsel and any self-represented parties shall work together to prepare and file a joint list of proposed jury instructions (in the format set forth below) which states, as to each proposed jury instruction: (1) the jury instruction number (listed in numerical order), (2) the title of the jury instruction, (3) the party requesting the jury instruction, (4) whether the jury instruction is agreed upon or contested, (5) a concise statement of any objection, and (6) whether the jury instruction was given by the Court (Joint List of Proposed Jury Instructions).

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 15
|SectionE. JOINT LIST OF PROPOSED JURY INSTRUCTIONS (JOINT AND CONTESTED)
Filing RequirementsMandatory

For Jury Trials, the parties' counsel and any self-represented parties shall work together to prepare and file a brief, joint written statement of the case for the Court to read to the jury. (Local Rule 3.25, subd. (g)(4).) Parties should not insist on particular wording for the other parties' contentions but should simply focus on their own contentions and their responses.

Filing RequirementsMandatory

Counter-designations in the joint chart must include columns for the witness number/name, date and type of testimony, page and line counter-designations, objections, the related designation number, and the Court's ruling.

Court's wording

In the joint chart, each counter-designating party's counter-designations of additional deposition or former testimony of the witness that relates to the designations shall include columns which state: (1) the designation number and name of the witness, (2) the date and type of testimony (e.g., deposition or trial testimony), (3) the page and line counter-designations of the deposition or former testimony requested to be used, (4) any objections, (5) the designation number of the other party's designation to which the counter-designation relates, and (6) the Court's ruling.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 16
|SectionH. JOINT CHART OF PAGE AND LINE DESIGNATIONS FOR DEPOSITION AND FORMER TESTIMONY
Filing RequirementsMandatory

Designations in the joint chart must include columns for the witness number/name, date and type of testimony, page and line designations, objections, related counter-designations, and the Court's ruling.

Court's wording

In the joint chart, each designating party's designations of deposition or former testimony shall include columns which state: (1) the designation number and name of the witness, (2) the date and type of testimony (e.g., deposition or Trial testimony), (3) the page and line designations of the deposition or former testimony requested to be used, (4) any objections, (5) whether the other party has counter-designated any additional deposition or former testimony of the witness that relates to the designation, and, if so, the designation number of the counter-designation, and (6) the Court's ruling.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 16
|SectionH. JOINT CHART OF PAGE AND LINE DESIGNATIONS FOR DEPOSITION AND FORMER TESTIMONY
Filing RequirementsMandatory

Parties intending to use deposition or former trial testimony must meet and confer and jointly file a chart of page and line designations; testimony used only for impeachment need not be included.

Court's wording

If any parties intend to use deposition testimony or former Trial testimony in lieu of or in addition to a witness's live testimony, the parties' counsel and any self-represented parties shall meet and confer to discuss, and work together to prepare and file, a joint chart in the format set forth below (Joint Chart of Page and Line Designations for Deposition and Former Testimony). The parties do not, however, need to include in the joint chart deposition testimony or former Trial testimony they plan on using for impeachment purposes only.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 16
|SectionH. JOINT CHART OF PAGE AND LINE DESIGNATIONS FOR DEPOSITION AND FORMER TESTIMONY
Filing RequirementsMandatory

Motions in Limine shall be noticed for hearing at the Final Status Conference. The parties’ counsel and any self-represented parties shall comply with the statutory notice provisions of Code of Civil Procedure §1005 and file declarations that comply with the requirements of Local Rule 3.57

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 17
|SectionMOTIONS IN LIMINE BINDER
Filing RequirementsMandatory

Parties filing more than one motion in limine shall number them consecutively.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 18
|SectionMOTIONS IN LIMINE BINDER
Filing RequirementsMandatory

Parties filing opposition and reply papers shall identify the corresponding motion number in the caption of their papers.

Document
Motion in limine opposition and reply
Placement
Caption
Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 18
|SectionMOTIONS IN LIMINE BINDER
Filing RequirementsMandatory

The parties shall organize proposed jury instructions into groups behind Tab F in the following order (labeled by cover sheets): (1) the agreed-upon instructions, (2) the Plaintiff's requested instructions to which the Defendant objects, and (3) the Defendant's requested instructions to which the Plaintiff objects.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 19
|SectionTrial Preparation Order (Trial Binder)
Filing RequirementsMandatory

Trial binders must include the specified documents under Tabs A through I, with bench (non-jury) trials requiring only Tabs A, B, C, H, and I.

Document
Trial binder

Must include

  • Exhibit list

Court's wording

following (for Trials by the Court without a jury, the Trial Binder shall only include the documents listed under Tabs A, B, C, H, and I): Tab A: Trial Briefs (Optional. If no Trial briefs are filed, leave Tab A empty.) Tab B: Joint Witness List Tab C: Joint Exhibit List Tab D: Joint Statement to Be Read to the Jury Tab E: Joint List of Jury Instructions Tab F: Joint and Contested Jury Instructions (full text adapted to the case and with all decisions as to bracketed matter duly incorporated). Tab G: Joint or Contested Verdict Form(s) Tab H: Joint Chart of Page and Line Designations for Deposition and Former Testimony Tab I: Copies of the Current Operative Pleadings (including the operative Complaint, Answer, Cross-Complaint, if any, and Answer to any Cross-Complaint.)

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 19
|SectionTrial Preparation Order (Trial Binder)
Filing RequirementsMandatory

The Trial binder shall be labelled on its FRONT and SPINE with the notebook title, the case caption, and case number.

Document
Trial binder

Must include

  • Caption
  • Case number
Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 19
|SectionTrial Preparation Order (Trial Binder)
Filing RequirementsMandatory

Any claims of privilege relating to the information required to be provided under this Order shall be made no later than the time information is required to be provided under this Order and shall be supported by a privilege log.

Filing RequirementsImportant

The witness list time totals, combined with estimates for jury selection, openings, closings, and jury instructions, should match the parties' total estimated trial time and any time limits set at the Case Management Conference.

Court's wording

The total time shown in the witness list may serve as part of the Court's basis for setting time limits at Trial and together with estimated time for jury selection, opening statements, closing arguments, and instructing the jury should match the parties total estimated Trial time and should match the anticipated date to present the case to the jury. The total time should also meet the time limits the Court set (if any) at the Case Management Conference ("CMC").

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 13
|SectionTrial Procedures - B. Joint Witness List
Filing RequirementsImportant

The parties should not request CACI instructions that do not apply when the Trial begins. For example, CACI 5013 shall not apply unless and until there is a deadlocked jury. During Trial, if circumstances change, the parties may request additional applicable jury instructions.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 15
|SectionF. JURY INSTRUCTIONS (JOINT AND CONTESTED)
Filing RequirementsImportant

if there is an appropriate CACI special verdict form for a cause of action, affirmative defense, or other finding, the Court expects the parties to use the CACI special verdict form. Any departure from a CACI special verdict form should be clearly explained.

Filing RequirementsImportant

An exhibit list should be provided at the front of the first volume of exhibits.

Document
Exhibit binder

Should include

  • Exhibit list
Filing RequirementsImportant

The parties should not file generic motions in limine untethered to actual anticipated disputes about evidence. Motions in limine that seek rulings “which would merely be declaratory of existing law” and do not include a discussion about the particular evidence the moving party seeks to exclude are not appropriate. (Kelly v. New West Federal Savings (1996) 49 Cal.App.4th 659, 670-671.) A common example is to seek exclusion of all evidence not produced in discovery. Such a motion is too abstract. Instead, a proper motion would seek to exclude specific evidence clearly sought in a particular discovery request or clearly ordered by the Court and yet not disclosed.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 18
|SectionMOTIONS IN LIMINE BINDER
Filing RequirementsImportant

New exhibits offered in Trial that have not been pre-marked should conform to the requirements above and should be identified on a supplemental exhibit list added to each copy.

Document
Trial exhibits

Should include

  • Exhibit list
Filing RequirementsNote

Exhibits to the statement may include declarations, proofs of service of the discovery requests at issue, and other documents.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 9
|SectionForm of Joint Discovery Dispute Statement
Filing RequirementsNote

If allegations made in a prior filing are relevant, the filing should be cited by name, date filed, and page and line.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 9
|SectionForm of Joint Discovery Dispute Statement
Filing RequirementsNote

Where the arguments for multiple discovery requests are the same, those arguments should be stated once after the group of requests and responses to which they apply.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 9
|SectionForm of Joint Discovery Dispute Statement
Filing RequirementsNote

Each party may, but is not required to, file a Trial Brief succinctly identifying: (1) the claims and defenses that remain in dispute for Trial; (2) the major legal issues (with supporting points and authorities); (3) the relief and calculation of damages sought; and (4) any other information that may assist the Court at Trial.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 13
|SectionTrial Procedures - A. Trial Briefs (Optional, but Encouraged)
Filing RequirementsNote

Parties should consider and may suggest the order of jury instructions; the Court typically reads CACI 100 and 200 series before opening statements or evidence, other instructions before closing argument, and some CACI 5000 series after closings.

Court's wording

The parties should consider the order in which they want instructions read. The Court typically reads all requested CACI series 100 and 200 instructions before the opening statements or before evidence is taken. All other instructions are usually given before closing argument, although some CACI 5000 series instructions should be given after closings. The Court invites the parties' suggestions on the order of jury instructions.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 15
|SectionF. JURY INSTRUCTIONS (JOINT AND CONTESTED)
Filing RequirementsNote

To the extent any party is seeking more time than allowed by the Court's limitations, that party should submit a discussion of proposed witness testimony either in the joint witness list or stating how much additional time is requested.

Ca Lasc Courtroom LAM 506 · Jun 2026 · p. 13
|SectionTrial Procedures - B. Joint Witness List

Filing & Service rules

Electronic Filing Rules

All documents must be electronically filed unless the litigant and filing qualify for an exemption under the First Amended General Order re Mandatory Electronic Filing for Civil (May 3, 2019).

All documents must be electronically filed unless the litigants and filings qualify for an exemption pursuant to the First Amended General Order re Los Angeles Superior Court – Mandatory Electronic Filing for Civil, dated May 3, 2019.

Page 2 | General Information

Filing Timing and Cure Windows

Ex Parte Applications must be filed by 10:00 A.M. on the court day prior to the Ex Parte hearing, absent an exemption.

Absent an exemption, you must file the application by 10:00 A.M. on the court day prior to the Ex Parte hearing.

Page 3 | Law & Motion

Case Management Statements must be filed at least seven calendar days before the scheduled Case Management Conference.

Case Management Statements must be filed at least seven calendar days before the date scheduled for the conference.

Page 4 | Case Management

Supplemental memoranda of law must be filed no later than ten days before the hearing date.

After the Joint Statement is filed, each party may file a supplemental memorandum of law not later than ten days before the hearing date.

Page 9 | Supplemental Memorandum

No later than five court days before the Final Status Conference, the parties' counsel and any self-represented parties shall file and serve the following documents:

No later than five court days before the Final Status Conference, the parties' counsel and any self-represented parties shall file and serve the following documents:

Page 13 | Trial Procedures - Final Status Conference

Service and Proof of Service Rules

The moving party's counsel must deliver its portion of the joint statement, with all supporting declarations and exhibits, to opposing counsel by personal delivery, e-mail, or fax.

Counsel for the moving party must personally deliver, e-mail, or fax to counsel for the opposing party the moving party's portion of the statement, together with all declarations and exhibits to be offered in support of the moving party's position.

Page 9 | Preparation of Joint Statement

After the moving party assembles the full statement, opposing counsel must sign it and return it by the end of the next business day so it can be filed with the notice of motion.

After the opposing party's material is added to the statement by the moving party's counsel, the statement must be provided to opposing counsel, who must sign it (electronically or otherwise) and return it to counsel for the moving party no later than the end of the next business day, so that it can be filed with the notice of motion.

Page 9 | Preparation of Joint Statement

Within seven days of receiving the moving party's material, opposing counsel must deliver its portion of the joint statement, with supporting declarations and exhibits, unless the parties agree otherwise.

Unless the parties agree otherwise, within seven days of receipt of the moving party's material, counsel for the opposing party must personally deliver, e-mail, or fax to counsel for the moving party the opposing party's portion of the statement, together with all declarations and exhibits to be offered in support of the opposing party's position.

Page 9 | Preparation of Joint Statement

Counsel and self-represented parties must exchange all exhibits they intend to introduce at trial no later than 18 calendar days before the Final Status Conference.

No later than 18 calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall exchange all exhibits they intend to introduce at Trial.

Page 11 | 1. MEET AND CONFER

Both parties must serve verifications along with the documents they produce in discovery.

Plaintiff and Defendant shall serve verifications with the documents they produce.

Page 22 | 3. Production of Documents

Discovery information may, at the producing party's option, be provided to the opposing party electronically as a PDF.

The information may be provided to the opposing party in electronic form as a PDF at the option of the producing party.

Page 22 | 3. Production of Documents

Filing Fees and Waivers

A party with a fee waiver under California Rules of Court, Rule 3.55(7) may request an official court reporter by filing local form LACIV 2699 in advance of the hearing or trial.

A party who has received a fee waiver pursuant to California Rules of Court, Rule 3.55(7) may request an official court reporter by filing local form LACIV 2699 in advance of the hearing or Trial.

Page 2 | General Information

Courtesy Copy Requirements

Courtesy copies are not accepted except for Oppositions to Ex Partes, MSC settlement briefs, or as otherwise requested, and any accepted copies should be emailed to the Department 506 Resource Account.

The Court does not accept courtesy copies except for Oppositions to Ex Partes, settlement briefs for Mandatory Settlement Conferences (MSCs), or as otherwise requested by the Court. Any courtesy copies should be submitted to the Department 506 Resource Account: smcdept506@lacourt.ca.gov.

Page 2 | General Information

One set of all Exhibit Binders must be brought to the Final Status Conference for the Court to review.

The parties’ counsel and any self-represented parties shall bring one set of all of the Exhibit Binders discussed above to the Final Status Conference for the Court to review.

Page 18 | EXHIBIT BINDERS

At least five copies of the exhibits must be brought to trial: one for each party, the witness stand, the Judicial Assistant, and the Court.

At least five copies of the exhibits should be brought to the Trial: one for each party, one for the witness stand, one for the Judicial Assistant, and one for the Court.

Page 18 | EXHIBIT BINDERS

Sealing & Redaction Procedures

Unredacted versions of confidential filings submitted on eCourt must be emailed to the department resource account with a cc to all counsel/parties, except that copying the opposing party is not required for Certificates of Merit or confidential MSC statements.

Any confidential filings (including documents filed under a protective order and documents lodged conditionally) submitted on eCourt must have their unredacted versions emailed to the department resource account at smcdept506@lacourt.ca.gov with a cc to all Counsel/parties involved. However, copying the opposing party is not required for confidential documents related to Certificates of Merit or confidential Mandatory Settlement Conference (MSC) statements.

Page 2 | General Information

A party seeking protection for disclosed information must serve and file a proposed protective order within five days and meet and confer on agreeable language; otherwise the default is the Los Angeles Superior Court's standard protective order.

Confidentiality: If a party believes any of the disclosure of information under this Order should be subject to a protective order, that party shall serve and file a proposed protective order within five days of this order and the parties shall meet and confer as to agreeable language for the same. The default protective order will be the standard protective order provided by the Los Angeles Superior Court on its website.

Page 23 | Confidentiality

Filing Bundling Requirements

Parties must jointly prepare and lodge a Motions in Limine Binder in Department 506 no later than three calendar days before the Final Status Conference.

No later than three calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall jointly prepare and lodge in Department 506 a Motions in Limine Binder.

Page 18 | MOTIONS IN LIMINE BINDER

Parties must jointly prepare and lodge a physical Trial Binder in Department 506 no later than three calendar days before the Final Status Conference, marked with the case caption, number and title and consisting of one-sided, conformed copies.

No later than three calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall jointly prepare and lodge in Department 506 a physical Trial Binder, with the case caption, number and title on the front page and, consisting of one-sided, conformed

Page 18 | TRIAL BINDER

Pre-Motion Conference Requirements

Informal Discovery Conferences are not held in Department 506 (except rarely by special request), so motions to compel further discovery must be accompanied by a joint statement for discovery disputes per Exhibit A, along with a notice of motion and motion to schedule the hearing.

Informal Discovery Conferences (IDCs) are not conducted in Department 506 (except rarely by special request). You may file your motions to compel further discovery. However, the Court now requires the parties to also file a joint statement for discovery disputes (as outlined in Exhibit A) together with your motions. Please note that you still must file a notice of motion and motion to schedule your hearing date.

Page 1 | Revised Guidelines Effective June 1, 2026

Trial Counsel must meet and confer by telephone or video conference (or in person) to resolve or narrow discovery disputes before proceeding with a discovery motion.

Trial Counsel must meet and confer by telephone or video conference (or in person, when consistent with public health recommendations) to resolve or narrow further discovery disputes. If the disputes remain unresolved, Counsel may proceed with a motion.

Page 3 | Law & Motion

For motions to compel further responses, the moving party must meet and confer with opposing counsel, then reserve a hearing date and file a notice of motion and motion to secure the hearing date.

After meeting and conferring with opposing counsel, the moving party shall reserve a hearing date for the motion and file a notice of motion. A notice of motion and motion must be filed to secure a hearing date.

Page 9 | Commencing a Discovery Motion

Counsel and self-represented parties must meet and confer no later than 11 calendar days before the Final Status Conference to prepare required trial documents, attempt stipulations on exhibit authenticity/admissibility, motions in limine, and ultimate facts and legal issues, and attempt to settle the case.

No later than 11 calendar days before the Final Status Conference, the parties’ counsel and any self-represented parties shall meet and confer to do the following: (1) discuss and prepare the documents required in Sections 3.B. – H., below, and the Motions in Limine Binder, Exhibit Binders, and Trial Binder required in Sections 3 - 5, below, (2) discuss and make a good faith effort to stipulate to the authenticity and admissibility of each Trial exhibit, (3) discuss and make a good faith effort to stipulate to resolve each motion in limine, (4) discuss and make a good faith effort to stipulate to ultimate facts and legal issues, and (5) discuss and make a good faith effort to settle the case.

Page 11 | 1. MEET AND CONFER

Informal Discovery Conferences are not required and may not be scheduled unless specifically authorized by the Court.

Informal Discovery Conferences (IDCs) are not required and may not be scheduled unless specifically authorized by the Court.

Page 3 | Law & Motion

Adjournment & Extension Requirements

Parties must use the Court Reservation System (CRS) to continue or withdraw motions and must also call the courtroom so it is aware of the change.

Parties must use CRS to continue or withdraw motions; please also call the courtroom so we are aware of the change.

Page 3 | Law & Motion

Chambers Communication Rules

with the Court must be emailed to the Resource Account at smcdept506@lacourt.ca.gov with a cc to all Counsel/parties involved.

with the Court must be emailed to the Resource Account at smcdept506@lacourt.ca.gov with a cc to all Counsel/parties involved.

Page 3 | General Information

Documents of departments with no single judge listed

About Judge Thomas D. Long

Judge Thomas D. Long is a judge on the Superior Court of California, County of Los Angeles, the state trial court serving Los Angeles County.

This judge's procedures are published through the court's general rules.

Common questions about Judge Thomas D. Long's rules

Are courtesy copies required for Judge Thomas D. Long?

Details: by email. Courtesy copies are not accepted except for Oppositions to Ex Partes, MSC settlement briefs, or as otherwise requested, and any accepted copies should be emailed to the Department 506 Resource Account.

View ruleSource: page 2, section General Information

Does Judge Thomas D. Long require a pre-motion conference or letter before filing a motion?

For motions to compel further responses, the moving party must meet and confer with opposing counsel, then reserve a hearing date and file a notice of motion and motion to secure the hearing date.

View ruleSource: page 9, section Commencing a Discovery Motion

What page or word limits apply to supplemental memorandum before Judge Thomas D. Long?

Judge Thomas D. Long's rule states these limits: 5 pages. Supplemental memoranda are limited to five pages.

View ruleSource: page 9, section Supplemental Memorandum

What formatting rules apply to filings before Judge Thomas D. Long?

Judge Thomas D. Long's formatting rule includes binding tabbed 3-ring, at least five sets required: one for the court, one for the judicial assistant, one for the witnesses, and one for each party, jointly prepared by parties' counsel and any self-represented parties, and organized numerically. Parties must jointly prepare at least five sets of tabbed, numerically organized three-ring exhibit binders: one for the Court, the Judicial Assistant, the witnesses, and each party.

View ruleSource: page 18, section EXHIBIT BINDERS

What must be included with motion to compel further responses filings before Judge Thomas D. Long?

Parties must prepare joint statements when briefing discovery disputes on motions to compel further responses.

View ruleSource: page 3, section Law & Motion

What must be included with trial notebook filings before Judge Thomas D. Long?

Parties must arrange for a Trial notebook to be delivered to the courtroom and lodged prior to the Final Status Conference, prepared consistently with the Trial Preparation Order.

View ruleSource: page 4, section Trial Procedures

How may parties contact Judge Thomas D. Long's chambers?

The rule lists email smcdept506@lacourt.ca.gov. with the Court must be emailed to the Resource Account at smcdept506@lacourt.ca.gov with a cc to all Counsel/parties involved.

View ruleSource: page 3, section General Information

How does Judge Thomas D. Long handle sealed or redacted filings?

Process: file unredacted to chambers. Unredacted versions of confidential filings submitted on eCourt must be emailed to the department resource account with a cc to all counsel/parties, except that copying the opposing party is not required for Certificates of Merit or confidential MSC statements.

View ruleSource: page 2, section General Information

How do I request an adjournment or extension before Judge Thomas D. Long?

Parties must use the Court Reservation System (CRS) to continue or withdraw motions and must also call the courtroom so it is aware of the change.

View ruleSource: page 3, section Law & Motion

Does Judge Thomas D. Long require motion papers to be bundled?

Parties must jointly prepare and lodge a physical Trial Binder in Department 506 no later than three calendar days before the Final Status Conference, marked with the case caption, number and title and consisting of one-sided, conformed copies.

View ruleSource: page 18, section TRIAL BINDER

Is electronic filing required before Judge Thomas D. Long?

Yes. Electronic filing is required for the covered filings. All documents must be electronically filed unless the litigant and filing qualify for an exemption under the First Amended General Order re Mandatory Electronic Filing for Civil (May 3, 2019).

View ruleSource: page 2, section General Information

Are filing fees or waivers addressed before Judge Thomas D. Long?

The rule identifies fee waiver availability. A party with a fee waiver under California Rules of Court, Rule 3.55(7) may request an official court reporter by filing local form LACIV 2699 in advance of the hearing or trial.

View ruleSource: page 2, section General Information

When is a filing treated as filed before Judge Thomas D. Long?

The rule states a 10:00 A.M. filing cutoff. Ex Parte Applications must be filed by 10:00 A.M. on the court day prior to the Ex Parte hearing, absent an exemption.

View ruleSource: page 3, section Law & Motion

What rule applies to serving the opposing party before Judge Thomas D. Long?

Details: recipient: the opposing party. Within seven days of receiving the moving party's material, opposing counsel must deliver its portion of the joint statement, with supporting declarations and exhibits, unless the parties agree otherwise.

View ruleSource: page 9, section Preparation of Joint Statement
Complete rules summary for Judge Thomas D. Long

Courtesy copies are not accepted except for Oppositions to Ex Partes, MSC settlement briefs, or as otherwise requested, and any accepted copies should be emailed to the Department 506 Resource Account.

All documents must be electronically filed unless the litigant and filing qualify for an exemption under the First Amended General Order re Mandatory Electronic Filing for Civil (May 3, 2019).

Unredacted versions of confidential filings submitted on eCourt must be emailed to the department resource account with a cc to all counsel/parties, except that copying the opposing party is not required for Certificates of Merit or confidential MSC statements.

Parties must prepare joint statements when briefing discovery disputes on motions to compel further responses.

A party with a fee waiver under California Rules of Court, Rule 3.55(7) may request an official court reporter by filing local form LACIV 2699 in advance of the hearing or trial.

Informal Discovery Conferences are not required and may not be scheduled unless specifically authorized by the Court.

Parties must arrange for a Trial notebook to be delivered to the courtroom and lodged prior to the Final Status Conference, prepared consistently with the Trial Preparation Order.

Ex Parte Applications must be filed by 10:00 A.M. on the court day prior to the Ex Parte hearing, absent an exemption.

If the parties cannot agree on a joint settled statement, each party must submit its own version highlighting the differences and lodge the competing proposals the next morning before proceedings resume.

For motions to compel further responses, the moving party must meet and confer with opposing counsel, then reserve a hearing date and file a notice of motion and motion to secure the hearing date.

If allegations made in a prior filing are relevant, the filing should be cited by name, date filed, and page and line.

Where the arguments for multiple discovery requests are the same, those arguments should be stated once after the group of requests and responses to which they apply.

Disputed interrogatories and answers must be quoted verbatim in the joint statement, followed by each party's separately stated contentions.

The joint discovery dispute statement may not refer the Court to any other documents.

The title page of the joint statement must state the discovery cutoff date, final status conference date, and trial date.

Within seven days of receiving the moving party's material, opposing counsel must deliver its portion of the joint statement, with supporting declarations and exhibits, unless the parties agree otherwise.

Supplemental memoranda of law must be filed no later than ten days before the hearing date.

Counsel and self-represented parties must exchange all exhibits they intend to introduce at trial no later than 18 calendar days before the Final Status Conference.

Supplemental memoranda are limited to five pages.

Counsel and self-represented parties must meet and confer no later than 11 calendar days before the Final Status Conference to prepare required trial documents, attempt stipulations on exhibit authenticity/admissibility, motions in limine, and ultimate facts and legal issues, and attempt to settle the case.

The joint witness list must end with a grand total of all estimated witness testimony times, stated in weeks, days, hours, and minutes as appropriate.

For jury trials, counsel and self-represented parties must jointly prepare and file a brief written statement of the case for the Court to read to the jury, focusing on their own contentions rather than the other parties' wording.

A party seeking more trial time than the Court's limits allow should include a discussion of proposed witness testimony in the joint witness list or state how much additional time is requested.

Counsel and self-represented parties must jointly prepare and file an exhibit list with eight specified columns for each exhibit any party actually intends to offer at trial.

For Jury Trials, the parties' counsel and any self-represented parties shall work together to prepare a complete set of full-text proposed jury instructions, editing all proposed Judicial Council of California Civil Jury Instructions (CACI) instructions, inserting party names, and eliminating blanks and other irrelevant or inapplicable material. If there is an appropriate CACI jury instruction on a point of law, the Court expects the parties to request the CACI instruction instead of a specially prepared jury instruction. Any departure from CACI instructions should be clearly explained.

For jury trials, the parties must jointly prepare and file a joint list of proposed jury instructions stating, for each instruction, its number, title, requesting party, agreed/contested status, any objection, and whether it was given.

Designations in the joint chart must include columns for the witness number/name, date and type of testimony, page and line designations, objections, related counter-designations, and the Court's ruling.

if there is an appropriate CACI special verdict form for a cause of action, affirmative defense, or other finding, the Court expects the parties to use the CACI special verdict form. Any departure from a CACI special verdict form should be clearly explained.

Parties intending to use deposition or former trial testimony must meet and confer and jointly file a chart of page and line designations; testimony used only for impeachment need not be included.

Opposition and reply papers on motions in limine must identify the corresponding motion number in the caption.

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